STL represents both lenders and borrowers, designing structures to optimize tax outcomes and minimize withholding taxes across various debt-related transactions. Our experience ranges from bilateral loans with a single lender and borrower to multinational syndicated credit arrangements that involve multiple layers of debt. We have the background to provide specialized advice on international lending transactions, ensuring compliance and maximizing efficiency.
Services
Structuring: Our structuring services minimize tax liabilities and optimize interest deductions. We conduct a thorough analysis of withholding tax implications and ensure compliance with both domestic and international tax regulations. With our extensive experience in international transactions, we guide you on the tax considerations involved in cross-border lending.
Tax Certificates: We offer assistance in obtaining withholding tax certificates to apply treaty or other benefits to reduce withholding tax rates.
Interest Expense Deductibility: To optimize the financial arrangements of borrowers, we provide advice on the tax deductibility of interest expenses.
Tax Opinions: Our legal opinions will help you understand the tax implications associated with lending transactions or support a specific tax position.
Representation before Tax Authorities: We represent clients in securing tax authority rulings to ensure clarity and predictability in tax treatment.